Now comes the defendant in the
above-entitled
matter and moves that the Court order the Commonwealth, pursuant to
M.G.L.
c. 261, sec. 27A et seq., authorize expenses in the amount not to
exceed
Ten Thousand Dollars ($10,000.00) to retain experts to testify at trial
on behalf of the defendant.

The defendant states that the
requested
funds
are "reasonably necessary to assure [him] as effective a . . . defense
as he would have if he were financially able to pay" (M.G.L. c.
261,
sec. 27C(1), Commonwealth v. Lockley, 381 Mass. 156
(1980), Comm. v. Blazo, 366 Mass. 141 (1974), Comm.
v.
Bolduc, 10 Mass.App.Ct. 634 (1980)) his rights to equal protection
of the laws, to present a defense, and to due process of law as
guaranteed
by the 5th, 6th, and 14th Amendments to the United States Constitution
and by Article XII of the Declaration of Rights of the Massachusetts
Constitution.

In support hereof, defendant states
that
the expenditure
of funds for experts is reasonable and necessary, for the defendant has
not only incurred decimating debt in the defense of this case, which
began
by Complaint in District Court a few years ago and has continued in
this
Court since last year after indictment, and the companion divorce case,
which began in 19__, he has also prepared and seeks leave to file the
requisite
forms to be determined to be indigent by the Court.

Respectfully submitted,

Insert Caption

MOTION
TO PRECLUDE

ANY
AND ALL OF THE COMMONWEALTH'S
EXPERTS

WHO
ARE NOT IDENTIFIED BY APRIL
6,
1993

Now comes the defendant in the
above-entitled
matter and moves that the Court preclude the Commonwealth from
putting
on any expert witnesses who have not been identified to Defendant by
April
6, 1993.